Mod 3 - Processing & Tailings Storage

Dear Sir/Madam,

I wish to lodge an objection to the Dargues Reef Mine Modification 3 on both environmental and social grounds.

The application to use cyanide in the processing warrants more scrutiny than a mere modification. This proposal is more demanding of a new development assessment.

The use of cyanide processing and the construction of a large tailings dam in the headwaters of a major catchment servicing agricultural, rural residential, wilderness and eventually an estuarine environment, leaves a poor legacy for current and future generations.

The dynamic geography and the volatile micro climate of the site underlines the unsuitability of the modification proposal

Independent reports reinforce the inappropriateness of such a proposal in this situation

The proponents of the mine have breached the social licence negotiated with the local population in the initial development assessment when the use of cyanide on the site was categorically dismissed by the then applicants.

The policy of obtaining planning agreements on an incremental basis is a blatant miscarriage of the approval process and one that needs to be addressed by the regulatory authority. This modification application is a prime example of a transgression of the spirit and the essence of the original determination.

I trust the Planning Department will recognise the inadequacies of the measures to safeguard the environment and the lack of social licence to operate of the proposal.

Openly admitted by the applicant as non essential to the economic viability of the project, the determination on Modification 3 would seem obvious!

Yours sincerely

Lis Mertens

I wish to express my oposition to the Dagues Reef gold mine operated by Unity Mining.
The risk of a Cyanide spill into Mjors Creek which flows into the Deau and Moruya River far outways any possible benefit this mine could provide.
We hear of environmental disasters when the holding dams storing cyanide fail.There can be no guarantee the dam dam wall will never break or leach Cyanide into Majors Creek.The company does not have a good environmental record.
The benefits of this mine are minorand the risk far outways any benefit.The Dagues Reef gold resource only has 88kozs of proven resource.There are other resources in the indicated and inferred category but this resource is not major and may only mine for a few years if the application is successful.
The price of gold is about AUD$1537 an ounce on 25/8/2015.
Many gold mines hace costs over $1300 per ounce and some now closed down had costs as high as $2000 an ounce.The economic viablity of such a mine is questionable given that many financial experts predict the gold price to go down.I pose the question is the big gamble of a few dollars profit worth it when weighed up against the potential environmental damage that will affect humans health as well flora and fauna.
In conclusion I strongly suggest the risks involved for this mine to treat gold with Cyanide on site are far too great to grant approval.

I am concerned about the potential for significant contamination from heavy metals to our waterways if there is any failure in Unity Mining's tailings facility. The water quality can be compromised and will affect the food production and water quality in the Araluen, Deua and Moruya Rivers.
Food production is a long term industry in the area where as mining is dependent on the gold price and there is no guarantee that Unity Mining will be around for the long term. I believe that it is easier to prevent spillage rather than try to compensate if there is a failure in the system .

This project will effect us all very badly. Greed is making the world go crazy. If this goes ahead, I will lose all faith in the EPA, Government and Councils. Stop this foolishness.

I would like to register my personal opinion that this modification does not constitute an acceptable risk for those that live in the Braidwood Majors Creek Araluen area and beyond to have to take.

The processing of ore onsite and the enlargement of the tailings dam is unacceptable as a modification. Many people in the community are very unhappy about this (including myself) as we were promised on many occasions that there would be no processing on site and no cyanide would be used.

Our trust in Big Island Mining has eroded after this promise was broken, to the point that it seems very easy for us to fear even further modifications occuring that would see the Majors Creek mine become a regional processing facility for other ore mined in the region. This is completely unacceptable, causing great damage to the quality of life for many of the residents here who have no interest in being overshadowed by something so unnecessary and in such direct contradiction to the overiding social and environmental values of the area.

The approval for the original mining operation was tentatively given by the community after the promise of many good jobs and the promise of reduced noise and no cyanide to be used. Even this took a great deal of voluntary time and effort on behalf of the people who live here who have no other choice but to spend their time and money chasing around big companies making sure they dont pollute our homes and so we may have peace of mind it is a clean and well looked after area for ever.

Not just for 50 years or 100 years then leave the pile of sludge for the state government (read: us - the tax payer) to clean up. It is not a matter of when and how, we have the stress of the thing right here now. This IS emotional. People are emotional, stress of potential and or actual environmental damage is emotional and is already occurring. The property values of our homes are based on emotion. Confidance. Human happiness. While it is a very valuable thing to have jobs in any community, make no mistake - this mine will lead to the loss of jobs in other sectors.

Many of our citizens property and business values are on the line here. While some may prosper, most will not. People making an effort to farm interesting and value added products in our lovely region will move away and try their luck somewhere cleaner and safer.

Many have chosen this area for values that will be lost should the gold mine be processing gold on site, extending its life and increasing the size of tailings laying in wait at the top of the catchment. Clean water, quiet. People who care about the environment and the future of it, and the jobs in a growing worldwide smart sustainable future economy. Many people here have already conceded that they will try and live out the existing approval for the timeframe of the mine, largely given that ore will be processed elsewhere - accepting that there will be numerous truck movements to move the ore. Even this was preferable to on-site processing - let along onsite processing with cyanide. Small organic local clean green sustainable farms are a growing industry here. Many farmers (supported by State and Federal government initiatives) have worked hard to adapt to possible climate change and build a reputation as clean green producers. With a gold mine processing ore using cyanide at the top of the Deua River catchment under 15km from Braidwood - future buyers of produce will think twice before trusting the quality. Future buyers of property will, and have already thought twice.

A gold mine storing waste in our midst and using dangerous chemicals to mine and process ore is something that has and will continue to be a huge negative burden on our community.

I have serious concerns about the proposed tailings dam and onsite processing using cyanide. I should state I was originally opposed to the mine in its entirety and this modification to the plans has added further weight to my opposition.

I am led to believe that once Unity mining ceases operations, after a period of time the tailings dam will become the responsibility of the NSW state government. As a former public servant I have grave concerns about this. I can only imagine how the scene would unfold if, god forbid, the dam was to fail. A breach in the dam is noticed, several frantic calls are made to the council who in turn make several more frantic calls as they are passed from person to person until they can find the person in charge of the unfolding drama and more phone calls are made as they try to establish the protocols and on and on it goes. By which time, the spill is well on its way down the mountain and it's all too late.

If this dam were located on a flat area or desert, that would be a different matter. But to have one perched precariously at the top of a major waterway is nothing short of madness. Whatever measures have been put in place to reduce the risk, it makes no difference. We all know, this dam has a finite lifespan and it's too great a risk to take in this area.

Submission on EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054
July 2015

As a resident of Eurobodalla I object to this third modification
to the Dargues Reef Gold Mine Development Application.

The main danger with this project for those living in the Moruya River Catchment is the assumption that
there will never be failures in the design or running of the proposed processing plant. Long experience as a public servant responsible for capital works tells me accidents do and will happen.
It is astounding that, as with the original development application for the mine, there is no reference to or assessment of the risks posed to the drinking water supply for the almost 40 000 residents of Eurobodalla Shire who rely on water drawn from the Deua River system.
I consider that the proposed modification creates a pollution risk that is unacceptable to residents along the entire Moruya River catchment. The potential cost to our community
is too great and Unity is ignoring the threat to our well-being.

SITE SELECTION
It seems to me the site is unsuitable for the construction and operation of a gold processing plant using cyanide as a
leaching agent and a tailings storage facility for waste, as I understand these will have a high heavy metal content that will remain for ever.
The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya River are all used for domestic water supplies and agricultural purposes.
Pollution in these waterways would threaten the orchards and market gardens of the Araluen Valley and the precious water supply to Eurobodalla Shire.
The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold on the mine site has significantly increased the risk of environmental harm.
The site is also located in a highly sensitive, biodiverse area of NSW, and threatens wildlife drinking the water in Conservation Reserves and National Parks. I understand heavy metal pollution could also be carried into Batemans Marine Park by the Moruya River.
This mine is on a completely different kind of site to the Unity mine at Henty in Tasmania (which was not built by Unity) which should not be quoted as proof that this kind of processing plant at Dargues Reef will be safe.

UNNECESSARY MODIFICATION
I have read that Unity Mining has stated to shareholders and the ASX that the Dargues project is still viable if this
Modification is refused, but that processing on-site would add to the `economic robustness' of the project.
The EA confirms that the decision to process ore on site at Dargues Reef is a cost-saving measure.
It must surely be a material consideration that a small gain in Unity Mining's shares could come at a large cost to residents, businesses and endangered species from the pollution risks that arise with construction of this processing plant.
I consider this site is inappropriate for such a high risk construction, especially when there are viable alternatives,

MORE ASSESSMENT REQUIRED
I understand that recent studies show that cyanide trapped in gold-mine tailings causes persistent release of dangerous
metals (eg.lead) into the groundwater and surface water. This tailings facility is located in a drainage line where
any breach will lead to contaminated water draining into the Majors Creek, Araluen Creek, Deua and
Moruya River water systems.
Downstream water used for drinking or agriculture could become contaminated with dangerous heavy
metals.
At a minimum, assessment must be made of the consequences of small or large spillages of heavy
metal material downstream of the site.

97 Mullimburra Point Road
Bingi NSW 2537

25th August 2015




As residents of the Eurobodalla we object to this third modification to the Dargues Reef Gold Mine Development Application.
We believe that the assumption that there will never be failures in the design or running of the proposed processing plant is ridiculous - accidents do and will happen.
We are appalled that, as with the original development application for the mine, there is no reference to or assessment of the risks posed to the drinking water supply for the almost 40 000 residents of Eurobodalla Shire who rely on water drawn from the Deua River system.
For the reasons we have listed below we believe that the proposed modification creates a pollution risk that is unacceptable to residents along the entire Moruya River catchment. The potential cost to our community is too great and Unity is ignoring the threat to our well-being.
Regarding the site of the proposal, our specific concerns include:
* The site is unsuitable for the construction and operation of a gold processing plant using cyanide as a leaching agent and a tailings storage facility for waste with a high heavy metal content that will remain for ever.
* The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya River are all used for domestic water supplies and agricultural purposes
* Pollution in these waterways would threaten the orchards and market gardens of the Araluen Valley and the water supply to Eurobodalla Shire.
* The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold on the mine site has significantly increased the risk of environmental harm.
* It is also located in a highly sensitive, biodiverse area of NSW, and threatens wildlife drinking the water in Conservation Reserves and National Parks. Heavy metal pollution could also be carried into Batemans Marine Park by the Moruya River.
* This mine is on a completely different kind of site to the Unity mine at Henty in Tasmania which should not be quoted as proof that this kind of processing plant at Dargues Reef will be safe.
We believe the modification is unnecessary, specifically:
* Unity Mining has stated to shareholders and the ASX that the Dargues project is still viable if this Modification is refused but processing on-site would add to the `economic robustness' of the project.
* The EA confirms that the decision to process ore on site at Dargues Reef is a cost-saving measure
* A small gain in Unity Mining's shares could come at a large cost to residents, businesses and endangered species from the pollution risks that arise with construction of this processing plant.
* This site is inappropriate for such a high risk construction, especially when there are viable alternatives.
Regarding the proposed enlarged tailings facility (TSF) itself our concerns include:
* If this plant is approved, dangerous heavy metals and cyanide residues left after the gold is extracted, will be stored forever as waste in a 16 hectare (40 acres) tailings storage facility. It will be built on steep land situated above a vital waterway and threaten people and businesses below.
* Recent studies show that cyanide trapped in gold-mine tailings causes persistent release of dangerous metals (eg.lead) into the groundwater and surface water. This TSF is located in a drainage line where any breach will lead to contaminated water draining into the Majors Creek, Araluen Creek, Deua and Moruya River water systems
* Downstream water used for drinking or agriculture could become contaminated with dangerous heavy metals
* At a minimum, assessment must be made of the consequences of small or large spillages of heavy metal material downstream of the site.
* More information on seepage from the TSF through the liner is required before Unity can dismiss either long term impacts from cyanide use or possible impacts at some distance downstream of the mine.
* There is no assessment of the risk of heavy metals in the Majors Creek, Deua River and Moruya River water systems.
* Further details of the likely chemical composition of the tailings and the impacts on groundwater or surface waters also needs to be added to the EA.
The introduction of this type of processing makes the composition of the tailings more poisonous and we agree with the EPA that a full risk assessment needs to be done which addresses all environmental risks associated with the TSF. This should include consideration of moving the TSF to a more appropriate part of the site which happens to lie in the Shoalhaven River catchment.
We are aware that correspondence obtained through GIPAA reveals the unsatisfactory response from Unity that this is not justified as the company is "merely seeking to modify an already approved TSF layout." We are even more alarmed that another Unity response ignores the risks focuses only on difficulties for the company i.e. "The suggestion to relocate has no understanding of technical or financial implications. It was extensively considered and rejected during original EA. Clearly Unity is insisting on this site for commercial convenience.
Further, we are appalled at the excuse that "Construction of TSF in Greater Shoalhaven River Catchment was not considered in the original DA because this catchment forms a component of Sydney drinking water catchment and any proposal there would have imposed additional regulatory requirements." This treats the residents of the Moruya River catchment as second class citizens and less worthy of protection.
We believe that little attention has been paid in the EA to the possible impacts to human health and downstream aquatic organisms resulting from a catastrophic failure of the TSF such as a breach of the wall. Unity has acknowledged that the TSF may fail and discard the tailings solids as a result of poor construction, or seismic activity in excess of design criteria, or erosion as a result of failure of the emergency spillway but that these possibilities have not been included in the risk assessment done by the company. Unity merely says that the consequence category of a TSF breach is "significant" and that the design criteria are appropriate for this rating. This is not acceptable.
A model of what could happen in a TSF failure needs to be included. The claim by Unity CEO that structures built in Australia do not fail because they are well built is incorrect. The Ranger's uranium mine tailings dam has spilled into the Magella Creek wetlands more than once. There have been various recent examples of such failures overseas.
Our concerns regarding the dangers from potential spillage from the enlarged TSF include:
* The ridge on which the mines sits is frequently subjected to heavy rainfall that does not fall elsewhere. Long term rainfall records for properties surrounding the site reveal that Unity estimates of magnitude of stormwater levels are too low.
* EPA has asked for this additional local information to be fed into the original climate model which it regards as insufficient for accurate prediction of rainfall conditions. This still needs to be done.
* The EA appears to allow for one to two spills per year but this is based on data that severely underestimates actual rainfall at the site.
* Since there is no mechanism to divert for spill water from the TSF it would flow in Spring Creek and the Majors Creek system. This is not acceptable.
* It is acknowledged that spillages can contain copper and mercury that exceed safe levels by two to five times in a 1 in 200 year, 72 hour rainfall event. The risk of a build-up of copper and mercury in the soil where crops that are irrigated with contaminated water is very real. . There is also a danger of build-up in the soil downstream from even minor spillages over a period of years.
Other risks we are concerned about and which add to the case against approving this modification include:
* The EA concentrates on cyanide risks but there are number chemicals used in gold recovery process. Details of discharge concentrations on all of these chemicals are needed for full assessment of the environmental risks of project.
* The company proposes to pump any polluted leakage back into the TSF. This assumes that the company will operate at or care for the site indefinitely. This will not be the case, whether the company ceases to be a commercial entity, is sold on or becomes bankrupt. Any construction must ensure that the site is safe without active and expensive ongoing management by the company and its successors or the NSW state government.
* The EPA says that sediment and erosion control needs to meet higher standards. The sediment dams must be an adequate size and the safe discharge of flocculent treated water should be a priority. Currently this treated water is pumped onto grassland but contamination of Majors Creek is possible due the sites unique combination of sudden severe storms, long periods of rainfall and soil porosity.
* The Modification needs to consider the measures that would need to be taken if there were to be a spillage of the cyanide products or its by-products, within the site but outside the bunded area.
As noted above we believe there are poor economic arguments being proposed in favour of this modification. In opposing it we believe that:
* The livelihoods of the residents across the entire Moruya River catchment are dependent upon the health of their soil, air and water for farming, aquaculture, tourism and environmental conservation.
* Araluen Valley has niche market stone fruit orchards, located directly downstream of the mine within 8km of the mine's proposed tailings dam. These orchards, along with cattle production, are the backbone of the rural enterprises along the catchment.
* Currently, this productive valley and the Deua waterway generate significant income and support an increasing level of employment, which will be put at risk if the proposed modifications are approved.
* The 40 000 residents in Eurobodalla rely on an unpolluted catchment for the water supply essential to their livelihoods.
* It only takes one accident or bad work practice at the mine to destroy this water supply.
* There has been no study of the number of people at risk downstream, nor what the economic damage may be either from a series of small or from one major spill.
* Property and businesses worth millions of dollars is at risk. Who will pay for any damage?
* It is worth noting the warning in the auditor's report in the September and December 2014 quarters about the material uncertainty that may cast significant doubt about the Company's and Consolidated Entity's ability to continue as a going concern and therefore, the Company and Consolidated Entity may be unable to realise their assets and discharge their liabilities in the normal course of business.
Unity Mining's operational record does not inspire confidence. They have already proven themselves to be prone to accidents on the Dargues Reef steep site. The environmental track record at this site is appalling and there is no reason to think it will improve. There were five pollution incidents in the six months they were in operation. Unity was prosecuted in the NSW Land and Environment Court where three of them attracted fines and costs totaling $200,000.
Those living downstream and close to the site had to repeatedly quarantine their water supply, dispose of polluted water safely and repair pumps damaged by grit. The proposed changes to the existing development approval threaten far more jobs and income than the six to ten million dollars per year that Unity predicts will be added to the local and regional economy. These are trifling figures when weighed against the worth of clean water catchments and food production downstream.
Unity pushes the good record of their Henty Mine operation as evidence that they can construct a safe mine. The Henty site however was constructed as a showpiece by another company. The Dargues Reef proposal is the first real test of their ability to develop a mine.
In 2014 Unity was also fined by the EPA in Tasmania for a spillage at Henty which had no contingency plan to deal with it.
Unity's Bendigo mine site has been left under care and maintenance rather than being properly closed down and remediated.
Finally we fear that if this modification is approved then further modifications will be likely. The processing plant will fundamentally change the economics of mining in this area. Other gold prospecting licenses are active across the region. It would only need one more modification application to extend the Dargues processing plant to accommodate any such new mines.
Unity have repeatedly told news outlets and the local public that it is not contemplating using the proposed plant to process gold from anywhere but Dargues Reef. However, the Chairman's Address to Annual General Meeting in 2014 contradicts this saying that it would be irrational for Unity to restrict use of its proposed plant to just one mine site.
In summary we believe:
* it makes no sense to risk irreversible damage to unique and precious environments, communities and economies of the Moruya River Catchment for the sake of a little more gold.
* Unity claims that this modification can be constructed and operated in a manner that would satisfy reasonable community expectations. Using this logic the modification should be rejected because it is a perfectly reasonable community expectation that the water supply for home and business use will not be subjected to the risk of dangerous and permanent contamination.
* There can be no guarantee that accidents will not occur. Neither the Department nor the EPA can constantly monitor the operations to ensure the continued safety of those downstream.
Thankyou for the opportunity to respond

Yours sincerely



Marcella Levey and Jim Herford
97 Mullimburra Point Road
Bingi NSW 2537
Ph: 44 736 580

I object to the proposed modification on the grounds that there is some risk of spillage from the tailings dam, particularly after extreme rainfall events. As this would impact on all the people downstream who rely on this river for drinking water, I consider the risk not worth taking.

This is a great opportunity for NSW and the local community at a time when our state needs it.

It will create local jobs and benefit small business in the community.

The company is a responsible operator and have gone to great lengths to ensure the mine is designed to the highest standards in terms of safety and environment.

Please consider the environment for now and the future in your decisions on this gold mine matter. The natural world in the face of poison and destruction is irreplaceable. Once destroyed it will not return in its current form. Profits from the mine will come and disappear in such a relatively short period of time but the cost of those profits will live on for an inestimable amount of time.
A healthy environment is our biggest asset and should not be dismissed lightly. It should be available to all rather than being used as a disposable commodity by a few.

I am opposed to any process that uses dangerous chemicals which I understand will be held indefinitely in a dam. I am concerned about evaporation into the atmosphere as well as the 'ticking time bomb' effect of the impending failure of the dam. Even if it doesn't affect me in my time, I care about the future generations and the effect on the environment etc. Jobs mean nothing if the planet we live on is a barren wasteland and we as a species need to protect an ever decreasing natural landscape.

The environmental mitigation measures for the proposed mine appear to be adequate and adequately consider the chance of any impact on surface and groundwater, endangered ecological communities and endangered species.

With this in mind, it is important to consider both the local and regional economic benefit that would be afforded to the community, as a result of this development. It is my understanding that the local community stands to benefit significantly from this proposal and that these benefits will be sustained over the medium to long term. On this basis, the economic benefits of this project should be taken into consideration, as they likely outweigh any potential environmental impacts and, with the correct conditions in place, this could be a very beneficial project for the community.

I was born in Braidwood and raised in Majors Creek. My mother still lives in my childhood home, and my father is buried in Majors Creek Cemetery. Wherever I may live, Majors Creek will always be my home.
I have been opposed to the gold mine in Majors Creek from the start. I understand the economic need for mining, but to see the countryside of my home dug up, developed and scarred has been heartbreaking for me. But I know the mine has approval and I accept this.
However, the approval that was originally granted was for the gold to be treated off site. This was the plan that the people, community, and government agreed to. The prospect of gold now not only being mined in Majors Creek but also treated there, fills me with great concern. I would even go so far as to say despair.
We all know that the chemicals used in gold extraction and treatment are highly toxic and damaging to the environment. We all know that these chemicals last for hundreds of years. We all know that "best practice" in transport and storage of these chemicals is still at the mercy of human error, and that although we may think we have safe methods for transport, storage and disposal of chemicals, we can be and often are, wrong. We all know that this company has had breaches in the past. We all know that not only is Majors Creek a beautiful community worthy of protection in its own right, but that it sits above the Araluen Valley, home to families, businesses, and rare and endangered animals, as well as pristine bushland. Not only this, but it is at the top of a catchment area that provides water to over a hundred thousand people. The damage that would be caused by a breach, a spill, an overflow, would be catastrophic.
There are simply too many risks to allow gold extraction to occur in Majors Creek.
Not only are the risks too great, but Modification 3 does not have community approval. The community agreed to the gold mine under the condition that gold would not be treated in Majors Creek, and as such there would be no chemicals transported, stored or disposed of in Majors Creek. The community did not and will not agree to Modification 3. I do not agree to Modification 3.

SUBMISSION

EA FOR THE DARGUES REEF GOLD MINE
MAJORS CREEK NSW 2622

APPLICATION 10_0054 MOD3


26th August 2015

The Department of Planning and Environment
GPO Box 39
SYDNEY NSW 2001

Attention Planning Services


Dear Sir/Madam

I am a resident of the Eurobodalla Shire concerned about the above application to allow the use of cyanide at the Dargues Reef Gold Mine. My submission focuses on the following issues:

1. The use of Cyanide
2. The impact on the aquatic environment downstream from Majors Creek to Moruya,
3. The impact on rural and domestic users of water from the Deua River and its tributaries, and
4. The impact on the Eurobodalla Shire's water supply.


The use of Cyanide

Sodium cyanide was declared a Priority Existing Chemical (PEC) by the National Industrial Chemicals Notification Assessment (NICNAS) in 2002 in response to environmental concerns based on reports of mass bird poisonings as a result of occurrences of the consumption of cyanide contaminated water of tailings dams.

The proposed method of gold extraction for the Dargues Reef gold mine is cyanide leaching and a tailings dam storage facility (TSF) on a steep escarpment at the headwaters of the Eurobodalla water system. This site is totally inappropriate for a TSF containing waste with a high heavy metal content that would remain for centuries.

This proposal to allow the use of cyanide is contrary to assurances given at the time of the development approval that,

"The processing plant will recover 50% of gold through a standard gravity process. It will comprise of a crusher, ball mills, gravity circuits and floatation cells.
A sulphide concentrate will be produced with the remaining gold. The plant will adopt a three-phase crushing and coarse grinding process. Cyanide will not be used, resulting in an environmentally friendly gold processing facility" (MiningTechnology.com)
Impact on the aquatic environment down stream from Majors Creek to Moruya

The proposed cyanide plant and smelter is at the headwaters of the South Coast's water system which is upstream from two conservation reserves, home to more than 20 endangered, vulnerable or critically endangered species, is a vital migratory corridor and the only safe permanent water for countless local species.

The release of cyanide contaminated water leached or spilled from tailings dams in the processing of gold has the potential to seep into underlying strata and groundwater resulting in contamination of downstream waterways and has been found to have a very high acute toxicity effect on aquatic life.

Dam failures resulting in toxic waste spills have had devastating consequences in Romania, China, Ghana, Russia, Peru, South Africa, and other countries. The 2000 Baia Mare cyanide spill in Romania, is estimated to have killed 1,241 tonnes of fish in Hungary alone, when 100,000 cubic metres of cyanide contaminated water, the result of a tailings dam failure, spilled into the Somes and Tisza rivers. Pollution flowed into the Danube and finally into the Black Sea.

There can be no guarantee that such events would not occur at the Dargues Reef mine, either as a result of human error or unprecedented weather events and have devastating impacts on the aquatic environment down stream from Majors Creek to Moruya


Impact on the rural and domestic users of water from the Deua River and its tributaries.

There are many properties along the Deua River and its tributaries dependent on the river for water resources, including town supply, rural domestic supply, stock watering, industry and irrigation purposes. Water sharing plans have been established to protect the environmental needs of the river and other water users to preserve water resources for the long term.

The Deua catchment provides about 60 per cent of drinking water to a regular population of around 40,000 and a combined resident/holiday maker population of over 100,000 during the summer months. For the rest of the year the Deua provides 100 per cent of the drinking water for the Eurobodalla shire The Tuross River is the other major source of water for the shire.

The consequences of a cyanide spill that would flow into the Deua river catchment would be devastating for the river environment and all those reliant on it for drinking water and local industries, especially the tourism and aquaculture industries worth over $340 million per year and representing almost 4,000 jobs, 25 per cent of the entire workforce.


Impact on the Eurobodalla Shire's water supply.

One of the primary goals of the World Health organisation (WHO) and its member states is that "all people, whatever their stage of development and their social and economic conditions, have the right to have access to an adequate supply of safe drinking water." A major WHO function to achieve such goals is the responsibility "to propose regulations, and to make recommendations with respect to international health matters ..." regarding the potential environmental and human health impacts of cyanide and cyanide compounds.

The US-based Mineral Policy Center has documented numerous cyanide spills at mining operations in recent years, including several accidents in the United States and others in Spain, Kyrgyzstan and Guyana. In several cases, the leaks have resulted in contamination of drinking water.
The possibility of contamination of the Eurobodalla Shire's drinking water as the result of toxic spillage resulting from the Dargues Reef gold mine would not auger well for the Shire's resident population or its reputation as a clean, green tourism destination.
Of greater concern are the potential environmental and human health impacts of cyanide and cyanide compounds.

Although fraught with possible catastrophic consequences, such risks do not appear to have been adequately addressed by the proponents.


Conclusion

The proposed modification to utilise cyanide in the extraction of gold at the Dargues Reef gold mine is for a short term operation that has no obvious economic benefits for either the Palerang or Eurobodalla shire, yet they would inherit the risk of potentially harmful long-term impacts on the aquatic environment, the rural and domestic users of water from the Deua River and the Eurobodalla Shire's water supply.

Who will be responsible for the long term environmental viability to the community, or the the potential financial burden on the NSW taxpayers over the full life-cycle of the project?

For the reasons stated above, I strongly believe that approval of Application 10_ 0054 Mod3 must not be granted.


Reina Hill

70 Long Beach Road
LONG BEACH NSW 2536

I object to this modification because
- The CEO of Unity Mining has stated publicly that the modification serves only to increase the profitability of the site.
- The assessments are not favorable and the most likely outcome is that the tailings dams will fail at some point in the future, requiring an expensive cleanup.
By the above, it follows that the company is attempting to draw down money at the expense of someone else, specifically the residents of Major's Creek of the future, my descendants included. This is not acceptable.

Submission for Dargues Reef Gold Mine Modification 3 MP_10 0054 July 2015

Myself and my family bought land with Deua River frontage on the Araluen Rd back in 1991 with the aim of raising a family in this beautiful location. Now a resident of the Deua River I am horrified to learn of the modification to the Dargues Reef gold mine development application.
The current danger with this project for us living on this river is that accidents could occur and today with flood warnings it could potential effect the tailings stability as has happened on previous occasions.
We pump from the river for the majority of our domestic water supply as well as watering our extensive market garden which supplies the majority of our everyday food produce .
I would therefore like to point out the risks to our livelihood and other residence of the Eurobodalla shire that these proposed modifications be not undertaken for the sack of precious clean water , verses non -essential gold.
Specific objections include:
INAPPROPRIATE SITE
* Pollution in these waterways would threaten ours and other market gardens along the Deua River.
* The EA map shows it is on a hill above a village and the headwaters to a beautiful river system.
MODIFICATION NOT NECESSARY
* A small gain to Unity mining shares could come at a large cost to residents, businesses and endangered species from the pollution risks that arise from its constructions.



ENLARGED TAILINGS STORAGE FACILITY
* Downstream water used for drinking water or agriculture or horticulture could become contaminated with dangerous heavy metals.
DANGERS OF SPILLAGE FROM TAILING STORAGE FACILITY
* The EA appears to allow for one to two spills per year but this is based on data that severely underestimate the actual rainfall at the site. I know for a fact we have many massive rain events here.
ECONOMIC CONSIDERATIONS
* I as a residence of this river catchment have not been consulted on the consequences of an accident happening to the TSF. It would mean we could not use the water from the river to grow our vegetables and fruits trees and the current tank water situation on our property would not be enough to sustain our sustainable practices in periods of drought.
* If we cannot grow our own produce we are putting another strain on the economy.
DUBIOUS RECORD OF THE COMPANY
* I have seen several photos taken of pollution incidents which occurred in the first six months of Unity mining operations. If processing occurs with cyanides this pollution incident would be even greater.
So I repeat it does not make any sense for us to allow a processing operation to take place when the risk is greater than the end product. The end product does not help the environment only glorifies the rich. We need to look after the earth not take a chance on a unqualified guarantee that the operation is safe for all people and animals and plants that live in this diverse environment.

I wish to register my strong objection to Coastwatchers and SERCA Dargues Reef gold mine being granted any modification to its operations. In fact, this mine should be shut down immediately. The dangers it poses to the environment are far too toxic to even entertain the idea of allowing a mining venture in such an area. Jackie French, Senior Australian of the Year has explained the situation in detail and I would respectfully request her objections be heard and acted upon.

I oppose this application to have on site cyanide processing at Unity's Majors Creek gold mine, as the cyanide, heavy metals and toxic waste water in the tailings dam, have the potential to pollute the pristine water in the Deua River and endanger our Eurobodalla water supply. History is littered with tailings dam failures. When the mine is in care and maintenance, that threat will hang over future generations for hundreds of years. I cannot support any approval as it would be the most irresponsible decision I, the community or the Government could make. I totally oppose this development modification.

I am opposed to the mine at Majors Creek using cyanide to process gold. In the last week alone, I have seen over 200mm of rain fall on my property which is unusual. Our average monthly falls are around 56mm. With our weather patterns becoming increasingly erratic, I can't have faith that the tailings dam will not spill.

My concerns are supported by Roger Hosking, a very respected local weather man. He set about establishing a time line and accurate model based on 68 years of data in order to establish a likely freeboard needed to contain water in a dam located in the area. He believes the data used to create the dam walls are inaccurate.

Braidwood needs development, but development that's sympathetic with the community and the environment.